DISH Network in a recent letter to telecom regulator FCC said the proposed merger between Comcast and Time Warner Cable will negatively impact cable and broadband users.
“More than 54 percent of the country’s high-speed broadband connections would be controlled by the combined company, and all online video distributors would be at the mercy of Comcast-TWC,” said Jeff Blum, senior vice president and deputy general counsel for DISH.
# The chokehold over the broadband pipe would stifle future video competition and innovation
# Comcast-TWC will destroy OVDs. An OTT could still turn a profit if it were to suffer foreclosure at the hands of a standalone Comcast, but not if the effects of the foreclosure spread across both of the Applicants’ systems
# The applicants claim that a large number of subscribers leave Comcast today and therefore would also leave the new Comcast, too. This claim is the basis of the Applicants’ contention that the combined company would have no incentive to block or degrade OVDs.
# Starting in late 2013, the speed at which Comcast’s customers were able to access Netflix content dropped from about 2.1 Mbps in October 2013 to 1.5 Mbps in January 2014, a 25 percent decline. Comcast says that the incident produced an increase in Netflix-related customer calls. The customers who called Comcast to complain, however, appear to have been venting their anger at their powerlessness to choose another provider.
# The combined Comcast-TWC would control more than 54 percent of the broadband pipes in the United States that have speeds of at least 25 Mbps, and will be on a path to virtual dominance of the high-speed broadband market given that the combined company will pass nearly 70 percent of pay-TV households in the U.S.
# Comcast-TWC will affect competition in a number of ways. It will cause subscribers to leave the competing distributor in favor of Comcast-TWC; it will cause dissatisfied Comcast-TWC subscribers to stay put instead of losing their access to NBCU; and it will let NBCU extract higher prices for its own programming by leveraging the fear of foreclosure.
DISH Network provides approximately 14.041 million pay-TV subscribers, as of Sept. 30, 2014,
